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What Financial Institutions and others are saying about the Proposed Rule to the “Unlawful Internet Gambling Enforcement Act of 2006.” “… given that there are several points requiring change or clarification, including the essential component – a definition of what transactions “unlawful Internet gambling” encompasses – several revisions must be made and a new rule proposed for further comment. Even then, major, fundamental flaws must be cured before effective implementation of the UIGEA can even be contemplated.” - American Banking Association “In general, we note that the proposed rule creates additional oversight responsibilities for financial services companies to undertake at a time when regulatory burdens have been shown to inhibit the competitiveness of U.S. financial institutions.” - Bank of America “The Chamber strongly encourages you not to approve the proposed collection of information associated with the UIGEA unless it fully complies with all statutory requirements.” - United States Chamber of Commerce “NAFCU strongly believes that the primary responsibility of depository institutions is, and should continue to be, the safe and sound provision of financial products and services and not to surveil consumers for criminal behavior or immoral activity.” - National Association of Federal Credit Unions “…our members continue to be very concerned that even with final adoption of our recommendations below, the rule could impose significant compliance burdens on financial institutions by increasing their role in policing illegal activities, determining whether a transaction is illegal, or by imposing ambiguous compliance requirements that could be subject to wide variations in interpretation by regulators and law enforcement agencies.” - The Financial Services Roundtable “We believe that the proposal, in its current form, is unworkable and cannot be implemented in a way that will produce measurable compliance in an objective fashion.” - Consumer Bankers Association “The definition of “unlawful Internet gambling” intentionally avoids defining particular gambling activity as legal or illegal.” - American Greyhound Track Operators Association “This regulation as proposed will create an undue burden on the financial industry as a whole.” - Farmers Capital Bank Corporation of Kentucky “The UIGEA does not prevent the agencies from reducing the paperwork burden on small businesses.” - Center for Regulatory Effectiveness “We believe that the regulation as proposed would create significant new compliance burdens for financial institutions without providing a commensurate public benefit consistent with the underlying statute.” - Sun Trust Banks, Inc, of Atlanta “BB&T believes the proposed regulation does not clearly define certain critical terms and is not clear on what is required of payment system participants in a number of areas.” - BB&T Corporation, which operates in the Carolinas, Virginia, Maryland, West Virginia, Kentucky, Tennessee, Georgia, Florida, Alabama, Indiana, and Washington, DC. “The regulations should have a provision that instructs the financial institutions that transactions for Interstate horse race wagering by states or state licensed entities are excluded from restricted transactions, should not be coded as restricted transactions, and should not be blocked.” - Nevada Pari-Mutuel Association “We urge you to include language that would specifically state that legal interstate parimutuel wagering transactions are not a violation of the Act.” - American Greyhound Racing, Inc., of Phoenix, Arizona “We believe the Proposed Regulation suffers from major problems that, in our opinion, make it unlikely that the purposes of the Act will be fulfilled.” - Compass Bank of Birmingham, Alabama “We also believe it is important for the Agencies to recognize that this proposed regulation, if not properly drafted, is likely to be a further springboard for litigation against banks…” - The Huntington National Bank of Columbus, Ohio “As soldiers who have been sent to fight and, in some cases, die promoting freedom abroad, we were particularly disheartened that Congress appears to have little regard for personal freedoms at home.” - Screaming Eagle Poker LLC of Clarksville, Tennessee “We further hope that this regulatory process will recognize the difference between skill games like poker and the games of chance that constitute traditional gambling.” - Screaming Eagle Poker LLC of Clarksville, Tennessee